On 7 April 2026, the AFM published its analysis on the use of AI in the Dutch asset management-sector. The AFM defines the following parties as asset managers: investment firms, fund managers, depositaries, proprietary traders and trading platforms.

The AFM states that the deployment of advanced/self-learning algorithms and other AI applications by asset managers is increasing. The analysis among 323 institutions shows that 53% of asset managers already use AI or intend to do so within a year. Especially larger fund managers and proprietary traders are leading in the adoption of AI.

AFM emphasizes that asset managers must remain transparent about the role of AI in their investment policies. The use of AI brings its opportunities but also comes with risks. Part of the sector is still insufficiently prepared for these risks: 26% has no policy for AI use, 35% has no technical and/or procedural controls for AI use, and for generative AI this applies to 72% of the participants. There is also room for improvement in the use of ethically responsible AI: 54% has no ethical handbook or code of conduct that specifically addresses AI.

Financial institutions have the responsibility to deploy AI in a careful manner. The current existing rules for controlled and ethical business operations also apply to AI applications (and their use). The AFM expects asset managers to actively work on identifying and managing risks associated with the development and use of AI, both in daily operations and in investment decisions. The report of 7 April also refers to the previous joint report of the AFM and DNB published in 2024. The joint report of 2024 can be found here.

AFM recommends to establish clear responsibilities in the development and implementation of AI solutions, documenting decision-making around AI-models, and implementing technical or procedural controls. The AFM will continue to focus on risk management with respect to the use of AI by asset managers in the coming period. This will also include examining how AI applications are deployed and monitored.

Read the press release and the full report here.